- 1. Foreword
HUESPEDIA wants to let its website users know about its policy regarding the personal information handling and protection for those people who voluntarily use e-mails as a means to contact us or any other service offered in the web that implies the communication of their personal information to HUESPEDIA.
To this effect, the term personal information means any information regarding identified or identifiable physical persons –including e-mail data and/or IP address-, whereas the term user means any identified or identifiable physical person who communicates his/her personal information to HUESPEDIA by using any service offered through the website of the mentioned company.
- 2. Identification of the business name of the file responsible
HUESPEDIA informs its website user that there is a personal information file or database whose responsibility lies on HUESPEDIA, C.B., domiciled at Poeta Artola, nº10-18ª, C.P. 46021, Valencia, where the personal information that the user communicates to HUESPEDIA is collected and saved.
- 3. Purpose of the personal information
HUESPEDIA does not request information from users who visit its website, therefore the communication of the user’s personal information to HUESPEDIA through the company website will only take place when the user voluntarily uses the e-mail service in order to contact us since, in this cases, the information handling is inevitable and is implicit to the communication system used by the user.
For these cases and the ones described in the next section “4”, HUESPEDIA notifies the user that the information is handled for the following purposes:
Perform all the operations related to the budget creation, HUESPEDIA hiring and service delivery to your company, or otherwise to the interested party who makes a request on his/her own behalf. Read and reply to all the communications received. Keep business relationship records.
- 4. Consent
HUESPEDIA informs its website users that this privacy policy contains all matters related to the personal information handling that HUESPEDIA, C.B. is responsible for.
Thus, when the user has no business relations with HUESPEDIA, he/she must be aware of and informed that sending an e-mail or communicating to HUESPEDIA any other personal information carries or implies that the user is giving free, unequivocal, specific, informed and express consent to the handling of his/her personal information, with the purposes stipulated in section “3” of this privacy policy, as well as to seeing to the user's communication or sending information to him/her. Otherwise, if the user does not agree with it, please refrain from sending e-mails or communicating your personal information to HUESPEDIA.
To the same effects, HUESPEDIA also informs that, if the user sends and e-mail or communicates his/her personal information due to the position he/she has in a company -either as administrator, manager, representative and/or any other position as the contact person in the company-, it will be assumed that such communication implies his/her free, unequivocal, specific, informed and express consent to HUESPEDIA handling his/her personal information, with the purposes stipulated in section “3” of this privacy policy, as well as to seeing to the user’s communication or sending information to him/her. Otherwise, if the user does not agree with it, please refrain from sending e-mails or communicating your personal information.
- 5. Requesting information
When the user, either on his/her own behalf, or on behalf or as contact of a legal entity, considers that the information provided in this policy is insufficient or lacks clarity, specificity or data, we do ask you that before sending an e-mail to us, and consequently your personal information, you request the additional information that you consider as necessary by sending us a written notice by snail mail to the address provided in section “2” of this policy.
- 6. Identification of the recipients to whom HUESPEDIA intends to transfer or communicate data
HUESPEDIA only intends to make data transfers or communications that, pursuant to article 11.2.c of Organic Law 15/99 on the personal information protection (hereinafter LOPD), must be made in order to comply with the obligations with Public Administrations when needed, according to the applicable Law governing every matter and every time, and as applicable, with other bodies such as Judges, Department of Public Prosecution, the Court, Court of Audit or People’s Defender.
Likewise, HUESPEDIA notifies the users that any other data transfer that needs to be done shall be informed to you, when stipulated by the LOPD, reporting expressly, accurately and unequivocally who the information recipients are, the purpose of the data and the nature of the transferred data or, when duly stipulated by LOPD, the unequivocal, specific and informed consent shall be requested to the user.
- 7. Other recipients of information
In spite of what is stated in the previous section, HUESPEDIA informs the user that any handling of personal information is subject to the governing Law of Spain with regard to data protection, stipulated by the LOPD and its complementary regulations.
In this sense, HUESPEDIA is just responsible for, and ensures the confidentiality, safety and handling of the data according to this policy, with regard to the data of personal nature requested to the user through its website www.huespedia.com, having no responsibility whatsoever in relation to the future handling and use of the personal data that could be done by other third parties who deliver social services of information which they might have access to as a result of the their service delivery or the exercise of their activities.
Third parties who deliver social services of the information mean –including but not limited to- those physical or legal persons who deliver the following services:
a) Transmission through a communication network the data provided by the service recipients. b) Services to gain access to the mentioned network. c) Data saving or hosting services. d) Contents or information supply.
Further, HUESPEDIA is not responsible for the handlings of data made by third parties who set hyperlinks with us, nor for those who link their visitors through hyperlinks to HUESPEDIA.
- 8. Data quality
HUESPEDIA warns the users that, unless there is a legally constituted representation, they cannot use another person’s identity nor can they communicate someone else’s personal information; therefore the user must at all times take into account that when using e-mail service, he/she can include only personal data regarding his/her own identity and that are correct, relevant, actual, accurate and true. To those effects, the user will be the only person responsible for any damage, either direct and/or indirect, caused to third parties or to HUESPEDIA resulting from the use o his/her own personal data or someone else's personal data when this information is false, wrong, non-existing, improper or irrelevant. Likewise, the user who utilizes the personal data of a third party will be responsible before the latter of the information obligation stipulated by section 5.4 of the LOPD, when personal data have not been collected from the interested party and/or of the consequences of not informing the third party about such use.
- 9. Minors and incapable data
If the user is a minor or incapable person, HUESPEDIA warns about the need to have the consent of their parents, guardian or legal representative for communicating their own personal data; therefore, we do ask you to refrain from using e-mail service if you do not have your parents, guardian or legal representative consent, and we are not otherwise responsible for the actions of the minor or incapable person.
- 10. Sending CVs to HUESPEDIA
HUESPEDIA warns the user that we do not want to receive CVs by e-mail; therefore we do ask the user to refrain from using e-mail service for sending this type of material at all times. Any e-mail containing this type of documents that we receive in our mailbox will be deleted and blocked before opening.
- 11. Data update
The user is the unique source of information regarding his/her personal data, therefore HUESPEDIA requests the user that, in order to keep his/her data updated at all times according to the Organic Law on the personal information protection (LOPD) provisions, the user must informs to the address specified for exercising access, amendments, cancellations, opposition rights, any variation of such data, as well as the termination of activities in the entity he/she represents, when appropriate, to proceed with the cancellation and/or historic handling of the information.
- 12. Exercising the opposition, access, amendment and cancellation rights regarding the data
HUESPEDIA informs the user of the possibility to exercise his/her access, amendment, cancellation and opposition rights, by sending a written request including his/her ID Document to the following address: Poeta Artola, nº 10-18ª C.P.46021, Valencia, or to a substitute address posted in the Data Protection General Registry.
- 13. HUESPEDIA use of the personal data collection forms
HUESPEDIA requests personal data to its website users through registration, reservations, subscription or information request forms, with the purpose of creating business relationships or answering their questions, or getting more information through the user. Pursuant to section 5 of the Organic Law on the personal information protection (LOPD), we inform you that the personal data collection will be solely for the purposes of providing the services you request, answering your questions or giving you more information, assuming that your data are provided voluntarily and with the user’s consent. In all cases, such data will not be subject to any handling whatsoever in our databases, nor will they be transferred to third parties.
- 14. Safety measures adopted in relation to personal data handling
HUESPEDIA informs the user that, pursuant to the provisions of the Organic Law on the personal information protection (LOPD) and its Regulations, we have adopted technical and organizational measures necessary to ensure the safety of personal data and to avoid the alteration, loss, handling or non-authorized access, taking into account the technology conditions, the nature of the saved data and the risks they face, whether they come from the human action or a physical or natural medium, and that only personal data that meet the terms stipulated in the mentioned Regulations will be recorded in the files, with regard to their integrity and safety, and the integrity and safety of the handling centers, facilities, equipments, systems or softwares.
Likewise, HUESPEDIA ensures the user the professional confidentiality compliance with regard to the users’ personal data and the obligation of saving such data.
- 15. Policy for the data handling controller regarding de delivery of non-requested communications
HUESPEDIA notifies the user that the company does not have a policy regarding the data handling for the delivery of non-requested communications due to the fact that this type of business activity is not performed. Should the circumstance change, we will inform the user in advance.
- 16. Recommendations for the users
HUESPEDIA recommends that the users implement the latest versions of softwares since these contain more safety measures.
Likewise, HUESPEDIA recommends that users use safety mechanisms that are available (secure web servers, cryptography, digital signature, firewall, etc.) in order to protect their data confidentiality and integrity, when necessary, since there is a risk of phishing or communications violation.
HUESPEDIA reminds users that Internet is not always as safe as we wish and therefore they must adopt all technical measures that are necessary and appropriate to avoid the non-authorized handling of their data.
HUESPEDIA warns users that whenever they provide personal information through Internet by e-mail, newsgroups, electronic forums, etc., they must be aware that such information may be collected and handled for purposes that are unwanted for the users, and therefore recommends that users learn about the confidentiality and privacy policies of the websites they visit.
HUESPEDIA warns the users to be aware that, unless coding mechanisms are implemented, Internet e-mail is not safe. E-mail messages and electronic forums may be a matter of identity fraud and phishing, which users must bear in mind whenever using this on-line applications. If you do not want to publish your e-mail address, you should set your browser’s configuration so that it does not leave your e-mail address recorded in the web servers you visit.
- 17. Policy update
HUESPEDIA will modify this privacy policy whenever necessary in order to adapt it to any legislation, regulation, jurisprudence or administration change, or to adapt such policy to the instructions provided by the Data Protection Agency or other legal object of HUESPEDIA.
In spite of what has been previously expressed, any modification of this policy shall be published and notified on HUESPEDIA website and in the policy itself, and each user shall take into account that the handling of his/her information will be governed –when informed to us- by the rules stipulated and applicable at the moment of communication.
With regard to all the above mentioned information, HUESPEDIA recommends that users read these policies regularly in order to know the changes made on them.